Calculating FTE for WEc2 & WEc3

In my humble opinion you are calculating transient occupancy correctly and classifying them logically as visitors for the reasons you state. However, since they are technically employees, not visitors, this may be the cause for the comment. Often providing a detailed narrative explaining your logic, calculations and approach are helpful to clarify situations that don't follow state requirements exactly. You might also try the calculation converting them to FTEs to determine impact. I suggest a conversation with your review team through the portal prior to re-submitting.